Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
Board
Board for Barbers and Cosmetology
chapter
Board for Barbers and Cosmetology Tattooing Regulations [18 VAC 41 ‑ 50]
Action General Review 2017 | Tattoo and Body-Piercing
Stage Proposed
Comment Period Ends 9/20/2019
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8/14/19  1:18 pm
Commenter: Abigail Thomas / Under The Sun Tattoo

Abigail Bowen/Under The Sun Tattoo
 

I have five topics I’d like to comment on.

The first is the “convention tattooer license” and the “guest artist license.” Traveling tattooists often want to do a guest spot in a local shop before or after a convention for financial or marketing purposes. I feel they should have the option to attend a convention AND do a guest spot without having to apply for two separate licenses. A tattooist should be able to obtain a “temporary tattoo license” that is valid for 2-4 weeks and they should be able to tattoo at any licensed parlor, permanent or temporary, in that time frame. A simple itinerary of where the tattooist plans to work, dates coinciding with the shop and/or convention they are attending, as well as a name, phone number and/or e-mail address of the responsible management that can confirm their travel plans. A couple of phone calls or emails from DPOR employees to confirm that the itinerary is correct should suffice in processing their application.

The second is in regards to the tattoo schools. My personal feeling about them is similar to a lot of professional tattooists in that it lowers the quality of tattooists coming into the industry. A lot of the graduates that come out of these schools are not always being trained properly in cleanliness, technique, or artistry, which is usually filtered through the apprenticeship method. Obviously, there are outliers because no system is perfect, but the general consensus with Tattoo Schools is negative in the community. However, we know that Tattoo Schools are here to stay and of course some are going to be better than others. 

At the 8.12.19 Town Hall Meeting I witnessed a Tattoo School owner who appeared, to me, to know little to nothing about tattooing. He didn’t even take the time to read about the proposed changes beforehand to be fully informed on what was going on at this meeting. His statements were ignorant in the ways of tattooing that it reenforced my feelings that Tattoo Schools need to be held to the same standards and potentially more scrutiny since there are many stories of fully-licensed tattoo school graduates who were not trained properly.

That is my main issue; tattoo schools are not held to the same standards as an apprenticeship. The instructors can be less qualified with only 3 years experience, have an unlimited number of students, and their required hours are literally half of an apprenticeship. I feel one-on-one attention from a mentor who has a personal interest in how their apprentice performs, and a 3 year tattooist with 10 students that can “teach them how to tattoo” in a 3 month course is not comparable. It’s a step in the right direction that DPOR requires tattoo schools to submit a curriculum, but I’m not sure any tattoo school curricula has been reviewed by an experienced tattooist. They may follow the basic guidelines set in the regulations, but those are only categories with no real definition of how in-depth these subjects should be taught. Only an experienced tattooist knows what is and isn’t important to teach their students, and a 3-year tattooist often does not have the experience, knowledge, or humility to be able to properly train students.

The reason, I believe, the apprenticeship method is superior to a tattoo school is because even though an apprentice may be fully “qualified” with their hours and trained to properly draw and apply a tattoo, the mentor is still very involved in their education. Those first two years of tattooing are full of learning curves. The scenarios are vast and it would take years of classroom work to try and cover them all, and you have an experienced mentor who can guide you through the process while you’re still under their tutelage. A tattoo school student passes their 3-month tattoo course and then are sent out into whatever shop will take them or, god forbid, they open their own shop; their education stops at 3 months. Tattoo schools are putting out people with a 3-month course who may or may not have the proper training with no one to guide them through the real part of their education, which is experience. A true tattooist is not out to create as many tattooers as possible to make a buck because we understand the ramifications of such actions.

My proposal is that tattoo schools should be held to the same standards to the apprenticeship. Tattoo School Instructors should have equal experience in tattooing to an apprenticeship sponsor (currently set to 5 years), equal required hours, and limiting the number of students per Tattoo School instructor.

The fourth issue isn’t really addressed in the regulation changes, but we would like to see it happen, is raising the permanent cosmetic tattooing required hours to match that of a standard tattooist (currently set to 1500, proposed to increase to 2000). I feel that all forms of tattooing should be equal in standard because it is inevitably making a permanent change to someone’s body. The clients are trusting that their tattooist has the proper knowledge and training to perform these changes and by raising the required hours could help ensure that. With the rising popularity of permanent cosmetic tattooing and the high-risk factor of damaging eyes and ruining people’s faces I see that as a reasonable request.

Lastly, I am with Gabe when I ask that at least all tattoo parlors (ideally all active tattooists) in Virginia be notified either through e-mail and/or letter of any regulation changes as well as relevant upcoming meetings. Most tattooists in Virginia don’t know that they have to sign up in order to receive these notifications and I feel it’s DPOR’s job to keep them up to date. We’ve tried to keep the ones in our circle in the loop, but ultimately a direct e-mail or letter would get their attention and ultimately more participation.

Thank you for your time.
-Abigail Bowen Thomas
Under The Sun Tattoo